Bank Found Negligent In Instituting Anti Money Laundering Policies

Case Overview

This case involves a bank in Chicago that served as a trustee to a large insurance company. The trust account contained eligible securities valued at $15 million. The bank subsequently allowed a third-party to deposit ineligible securities into the account and sell the good bonds. The third party was an investment adviser who worked with the bank to create the ineligible securities that were later deemed worthless. The authorities examined the bank and found it negligent in instituting proper policies and procedures in place for the anti-money laundering requirements of federal law.

Questions to the Finance expert and their responses

Please describe your experience in bank regulation and examination, specifically with the OCC, if applicable.

I have 35+ years of experience in financial institution supervision and compliance. I was a national bank examiner at the OCC for 30 years and an AML/CFT banking specialist for 20 years. I am also a certified financial crimes specialist, a certified fraud examiner, and a certified anti-money laundering specialist. During my career, I have reviewed the bank’s suspicious transactions identification, traced proceeds and transactions through several layers of activity, and reviewed a bank’s processes and procedures to determine root causes of AML/CFT program weaknesses.

About the expert

This expert has over 35 years of experience in the field of financial compliance, specializing in financial institution supervision. He earned his BBA from the University of Georgia and his MBS from the University of Texas. He is a commissioned national bank examiner, a certified financial crimes specialist, and a certified anti-money laundering specialist. He spent 30 years as a national bank examiner for the Comptroller of the Currency where he was a safety and soundness examiner and a compliance examiner. He specialized in AML and CFT examinations, where he analyzed a bank?s AML and CFT program to ensure that it complied with applicable banking laws, rules, and regulations. In addition, he reviewed the bank?s suspicious transactions identification, monitoring, and reporting process, traced proceeds and transactions through several layers of activity, and reviewed the bank?s processes and procedures to determine the root causes of AML and CFT program weaknesses. Currently, he serves as a banking consultant for an independent consultancy in Illinois.